Get Ready

There are a number of considerations you should take into account when determining how the Quality Payment Program (QPP) will impact your practice, and what options will be best for you and your patients.

Are you exempt under the MIPS low-volume threshold?

Individuals and groups that submit $30,000 or less in Medicare Part B charges or see 100 or fewer Medicare patients are exempt from MIPS in 2017. You can also check your and your practice's eligibility on CMS's website. In 2018, the threshold will increase to $90,000 or less in Medicare Part B charges or 200 or fewer Medicare patients.

Exempt physicians will receive a 0.5 percent payment adjustment to the Physician Fee Schedule in 2019 and no payment adjustment from 2020 to 2025 to the fee schedule. In 2026 and beyond, exempt physicians will see fee increases of 0.25 percent to the Physician Fee Schedule. MIPS reporting is voluntary for exempt physicians, but reporting won’t result in any additional payments.

Will the cost of reporting in MIPS exceed your negative payment adjustment?

If you are not exempt, you should carefully examine how the infrastructure and staff costs required for MIPS reporting compare to your greatest potential payment cut in each performance year:

2019, 4 percent,

2020, 5 percent,

2021, 7 percent,

2022 and beyond, 9 percent.

If you would report as an individual, check your previous year’s Medicare revenue to see how your practice would fare if you didn’t report and received the lowest possible score. If reporting as a group, you’ll need to aggregate the revenue received from Medicare across all reporting providers in the group.

Should you report as an individual or as a group?

Groups are identified by Tax Identification Number (TIN) and are defined as having two or more eligible clinicians who have reassigned their billing rights to the TIN. Consider whether reporting as a group may limit your ability to report on relevant quality measures if you’re in a multispecialty practice and whether multiple electronic health record (EHR) systems used by practices sharing the same TIN could complicate your reporting.

If you are part of a group with many low-volume Medicare providers, you may want to consider advocating that everyone in your group report as individuals since the same low-volume threshold is applied to both individuals and groups.

You will have to un-assign your billing rights to the TIN if your group opts to report as individuals. You cannot carve out low-volume providers from a group.